LIHWAP: A Primer for the Community Action Network

CAAs may use CSBG funds to supplement the services provided by LIHWAP and help clients manage their water-related needs, even after the LIHWAP program ends. However, the costs should otherwise be allowable and allocable to CSBG under applicable law, including the Uniform Guidance.

In addition to assistance with paying water bills, some households may require small-scale plumbing repairs such as fixing leaking pipes, updating fixtures (e.g., faucets, showers, or toilet fixtures), or replacing filters to remove contaminants from drinking water. Addressing these issues can help keep the household’s water bill low and reduce the possibility that they will fall behind in the future. OCS has clarified that these small-scale plumbing repairs are not subject to CSBG’s prohibition on using funds for the permanent improvement of any building or other facility (42 U.S.C. § 9918(a)(1)). Thus, CSBG may be used to address these household needs and to coordinate with other programs. This includes using CSBG CARES funds, since water affordability needs have been significantly exacerbated by the COVID-19 public health crisis and access to clean water is critical to reducing the transmission of the virus through hand washing. For more information on the distinction between ordinary repairs and permanent improvements to facilities, see CAPLAW’s Q&A on Property Issues.

CSBG funds may also be used for the coordination and delivery of other utility assistance benefits and household services (see LIHWAP DCL 2021-15). OCS has encouraged Recipients to use expedited procedures for modifying Community Action Plans to coordinate CSBG funding with LIHWAP efforts and provide additional household plumbing repairs or supports if needed (see CSBG DCL-2021-22).

This resource is part of the Community Services Block Grant (CSBG) Legal Training and Technical Assistance Center. It was created by CAPLAW in the performance of the U.S. Department of Health and Human Services, Administration for Children and Families, Office of Community Services, Cooperative Agreement Award Number 90ET0482-02. Any opinion, findings, conclusions, or recommendations expressed in this material are those of the author(s) and do not necessarily reflect the views of the U.S. Department of Health and Human Services, Administration for Children and Families.